This article expands on the meaning of reasonable time and place and examines numerous other rules governing audit examinations: (1) the significance of the taxpayer's last known address; (2) the rules governing representation before the IRS; (3) established channels for resolving difficult tax problems; (4) guidelines for disputing IRS findings; (5) IRS tools for collecting assessments of additional tax; and (6) the appropriateness of litigation in resolving assessment disputes. In addition, the Taxpayer Bill of Rights and the IRS initiatives to expand taxpayer rights are analyzed and explained. Tax practitioners with a working knowledge of these provisions will be better prepared to represent clients receiving that dreaded IRS audit notice.

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